Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 1 of 16
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`VOIP-PAL.COM, INC.
`
`Plaintiff,
`
`v.
`
`META PLATFORMS, INC., and
`WHATSAPP, INC.
`
`Defendants.
`
`
`VOIP-PAL.COM, INC.
`
`
`Plaintiff,
`
`
`
`v.
`
`
`GOOGLE LLC,
`
`
`Defendant.
`
`
`
`VOIP-PAL.COM, INC.
`Plaintiff,
`
`
`
`
`CIVIL ACTION NO. 6:20-cv-267-ADA
`
`
`
`CIVIL ACTION NO. 6:20-cv-269-ADA
`
`
`
`CIVIL ACTION NO. 6:20-cv-272-ADA
`
`v.
`AMAZON.COM, INC.,
`AMAZON.COM SERVICES LLC, and
`AMAZON WEB SERVICES, INC.,
`Defendants.
`
`
`
`
`PLAINTIFF’S SURREPLY CLAIM CONSTRUCTION BRIEF
`
`
`
`
`

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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 2 of 16
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`TABLE OF CONTENTS
`
`SURREPLY ARGUMENT .................................................................................................1 
`
`“network element[s]” .............................................................................................. 1 
`A. 
`“identifier[s]” .......................................................................................................... 3 
`B. 
`“first participant profile” ......................................................................................... 4 
`C. 
`“routing message” ................................................................................................... 6 
`D. 
`“private network” .................................................................................................... 7 
`E. 
`“gateway” ................................................................................................................ 9 
`F. 
`CONCLUSION ..................................................................................................................10 
`
`
`
`I. 
`
`II. 
`
`
`
`i
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`

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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 3 of 16
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`
`
`Cases
`
`TABLE OF AUTHORITIES
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`01 Communique Lab., Inc. v. LogMeIn, Inc., 687 F.3d 1292, 1297 (Fed. Cir. 2012) .................... 2
`
`Arlington Industries, Inc. v. Bridgeport Fittings, Inc., 632 F.3d 1246, 1254 (Fed. Cir. 2011) ...... 6
`
`Dealertrack, Inc. v. Huber, 674 F.3d 1315, 1327 (Fed. Cir. 2012) ................................................ 5
`
`Kara Tech Inc. v. Stamps.com Inc., 582 F.3d 1341, 1348 (Fed. Cir. 2009) ................................... 5
`
`MBO Labs., Inc. v. Becton, Dickinson & Co., 474 F.3d 1323, 1333 (Fed. Cir. 2007) ................... 7
`
`Spansion, Inc. v. ITC, 629 F.3d 1331, 1344 (Fed. Cir. 2010) ......................................................... 3
`
`TiVo, Inc. v. Echostar Commc’ns Corp., 516 F.3d 1290, 1303 (Fed. Cir. 2008) ........................... 2
`
`
`
`
`
`
`ii
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`

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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 4 of 16
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`TABLE OF ABBREVIATIONS
`
`
`ABBREVIATION
`
`TERM
`
`VoIP-Pal
`
`Facebook
`
`WhatsApp
`
`Google
`
`Amazon
`
`
`Defendants
`
`The ’606 patent or the patent-in-suit
`
`The ’234 patent
`
`The ’721 patent
`
`The Mobile Gateway patents
`
`RBR
`
`Mangione-Smith Decl.
`
`POSITA
`
`U.S. Patent App. No. 2014/0024367A1
`
`U.S. Pat. No. 7,486,684
`
`Plaintiff VoIP-Pal.com, Inc.
`
`Facebook, Inc.
`
`WhatsApp, Inc.
`
`Google LLC
`
`Amazon.com, Inc., Amazon.com Services,
`LLC, and Amazon Web Services, Inc.
`
`Facebook, WhatsApp, Google, and Amazon
`
`U.S. Patent No. 10,218,606
`
`U.S. Patent No. 8,630,234
`
`U.S. Patent No. 10,880,721
`
`The ’234 and ’721 patents
`
`Routing, Billing, Rating
`
`Declaration of William Henry Mangione-
`Smith
`
`Person of ordinary skill in the art
`
`Bjorsell
`
`Chu
`
`
`
`
`iii
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`

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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 5 of 16
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`I.
`
`SURREPLY ARGUMENT
`A.
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`“network element[s]”
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`VoIP-Pal maintains that a POSITA would understand the plain and ordinary meaning of
`
`“network element”—this simple term needs no definition.1 In light of the intrinsic evidence
`
`presented by VoIP-Pal, Defendants apparently now have abandoned some of their original
`
`arguments: (1) that the specification “never even uses the term ‘network element’”; and (2) that
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`the “specification discloses no comparison of the identity of network components.”2 Defendants
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`rest their argument now solely on the false proposition that “a POSITA would not understand the
`
`term’s outer bounds with reasonable certainty.”3
`
`While further definition of “network element” should not even be necessary, when VoIP-
`
`Pal suggests that “network element” would be understood as a “device or component of the
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`communication network associated with at least one IP address,” Defendants plead ignorance and
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`claim that a POSITA would not know whether the term encompasses multiple devices or “purely
`
`logical structures.”4 Despite what Defendants claim, Defendants are arguing that the claims are
`
`indefinite because they are too broad.5 Indeed, Defendants effectively admit that they are able to
`
`determine the bounds of the claims—the claims may cover a single and/or multiple devices and
`
`they may cover physical and/or logical structures. Yet the Federal Circuit has cautioned that
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`“breadth is not indefiniteness.”6 The alleged ambiguity that Defendants complain about does not
`
`render the claims indefinite.7
`
`
`1 See Dkt. No. 71 at 7, Dkt. No. 71-4 at ¶¶22-27. All Dkt. Nos. refer to docket entries in Case No.
`6:20-cv-269-ADA unless otherwise noted.
`2 Dkt. No. 67 at 5.
`3 Dkt. No. 75 at 14.
`4 Id. at 13.
`5 Dkt. No. 75 at 1 n.1.
`6 See, e.g., BASF Corp. v. Johnson Matthey Inc., 875 F.3d 1360, 1367 (Fed. Cir. 2017).
`7 Id. at 1365 (“‘Reasonable certainty’ does not require ‘absolute or mathematical precision.’”).
`1
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 6 of 16
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`Defendants have invented alleged indefiniteness problems from whole cloth. The
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`specification never cites a “logical structure” anywhere, nor did VoIP-Pal ever assert that “logical
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`[data] structures” have IP addresses (as per its definition). As Dr. Mangione-Smith explains, a
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`POSITA would know that “network elements” could be implemented as hardware or software.8
`
`Defendants wonder out loud if a “network element” may “not encompass any specific physical
`
`devices at all,” ignoring the fact that every example of network element in the specification has a
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`physical manifestation.9 As disclosed in the specification, a network element could be
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`implemented in software, but the use of software will involve the use of some physical hardware.
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`In short, Defendants create a cloud of faux uncertainty around intrinsic and extrinsic sources that
`
`show that a POSITA would reasonably understand the bounds of the term “network element.”
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`Defendants’ question of whether the term encompasses a single device or multiple devices
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`is likewise a meaningless smokescreen. A POSITA would know that a “device” can include other
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`devices and that a “component” can be made of other components. Furthermore, it is well-known
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`in claim drafting that a recited single claim limitation includes its plural, thus “a network element”
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`can include more than one network element.10 Thus, Defendants’ question is irrelevant.
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`Defendants falsely accuse VoIP-Pal of reworking its proposed construction of “network
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`element” from a prior litigation to include the word “component.”11 Rather, VoIP-Pal merely uses
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`the word “component” in discussing how the specification describes a network element.12 Figure
`
`1 of the specification shows the communication network as including network-addressable entities
`
`
`
`8 Dkt. No. 71-4 at ¶25.
`9 Dkt. No. 75 at 4.
`10 01 Communique Lab., Inc. v. LogMeIn, Inc., 687 F.3d 1292, 1297 (Fed. Cir. 2012) (quoting
`TiVo, Inc. v. Echostar Commc’ns Corp., 516 F.3d 1290, 1303 (Fed. Cir. 2008)) (“As a general
`rule, the words ‘a’ or ‘an’ in a patent claim carry the meaning of ‘one or more.’”).
`11 Dkt. No. 75 at 2.
`12 Dkt. No. 71 at 8.
`
`
`
`2
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 7 of 16
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`that a POSITA would fairly understand to be network “elements” or “components.”13 Defendants’
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`complaint that VoIP-Pal’s prior construction is inconsistent because the Valdar textbook describes
`
`network components that do not have a network address (e.g., cables) is irrelevant.14 Again, VoIP-
`
`Pal is not proposing its construction from the prior litigation—VoIP-Pal is proposing plain and
`
`ordinary meaning. The plain and ordinary meaning of “network elements” in light of the
`
`specification is consistent with VoIP-Pal’s prior proposed construction. Even Defendants admit
`
`that the examples of “elements” given in the specification all have IP/UDP addresses.15
`
`Thus, Defendants’ indefiniteness analysis is entirely contrived and is hardly sufficient to
`
`meet their burden to prove indefiniteness by clear and convincing evidence.16 The specification
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`discloses multiple examples of network elements and ways of implementation. As Dr. Mangione-
`
`Smith states, a POSITA would be able to understand the bounds of the term “network element”
`
`with reasonable certainty.17 Accordingly, the Court should reject Defendants’ indefiniteness
`
`argument and construe “network element[s]” as “plain and ordinary meaning.”
`
`B.
`
`“identifier[s]”
`
`Defendants reject the simple, plain and ordinary meaning of “identifier,” but instead seek
`
`a special, unsupported definition: “value with pre-defined format.” Defendants cannot refute
`
`VoIP-Pal’s point that the term “identifier” per se does not denote any particular predefined format.
`
`Instead, contrary to well-established Federal Circuit precedent, Defendants desperately try to read-
`
`in cherry-picked limitations from the preferred embodiment into the claims. Their attempt fails.
`
`
`
`13 Dkt. No. 67-3 at Fig. 1.
`14 Dkt. No. 75 at 14.
`15 Dkt. No. 67 at 14.
`16 See Spansion, Inc. v. ITC, 629 F.3d 1331, 1344 (Fed. Cir. 2010).
`17 Dkt. No. 71-4 at ¶¶22, 25.
`
`
`
`3
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 8 of 16
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`Defendants assert that the claimed new second participant “identifier” requires compliance
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`with a “predefined username format.”18 While such an identifier is one way of identifying a private
`
`network call, Defendants ignore that in the immediately preceding sentence, evaluating a “re-
`
`formatted callee identifier” is listed as an alternative way of identifying a private network call.19
`
`Second, a “callee identifier buffer” can hold different kinds of callee identifiers at different times.20
`
`Sometimes it holds a “username.”21 Other times, the “callee identifier buffer” holds a PSTN-style
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`phone number.22 The callee identifier type can change.23 Similarly, the stop message callee field
`
`1004 can hold different types of callee identifiers.24 And Defendants gloss over VoIP-Pal’s
`
`intrinsic evidence that a “caller identifier” can be a phone number, a username, or IP address.25
`
`The term “identifier” is a plain English word; it would be understood by a POSITA and a
`
`lay juror even apart from any examples from the specification. Defendants’ special definition is
`
`thus wholly unnecessary and should be rejected.
`
`C.
`
`“first participant profile”
`
`Defendants allege that a “profile” must include “information relating to a call participant
`
`in a PSTN system.” Yet the word “profile” per se does not imply the necessity of PSTN system
`
`information. In support of their special construction, Defendants cannot cite to any statement in
`
`the patent defining the term “profile” as limited to a PSTN system, nor to any well-known usage
`
`of the term in that manner. Defendants therefore attempt to define “profile” by cherry-picking
`
`
`18 Dkt. No. 75 at 4 (citing the ’606 patent (Dkt. No. 67-3) at 2:61-64).
`19 Dkt. No. 67-3 at 2:37-39 (“The process may involve formatting the callee identifier into a pre-
`defined digit format to produce a reformatted callee identifier”); see id. at Fig. 8B (item 402), 2:59-
`61, Fig. 8B (item 269).
`20 Id. at Fig. 7 (item 211).
`21 Id. at 21:3-6.
`22 Id. at 22:3-8.
`23 Id. at Fig. 8B (item 279).
`24 Id. at 35:32-33.
`25 Dkt. No. 71 at 10-11.
`
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`4
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 9 of 16
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`pieces from a specific embodiment, against legal precedent.26 With no sense of irony, Defendants
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`complain that VoIP-Pal’s counterarguments improperly “rely[] on a preferred embodiment to
`
`contort the meaning of the claims.”27 But VoIP-Pal is only highlighting that, absent Defendants’
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`cherry-picking, the preferred embodiments do not support Defendants’ construction of “profile”.
`
`Defendants emphasize that the specification discloses profiles identifying “calling
`
`attributes.”28 But this observation leads to nowhere for many reasons. First, there is no basis to
`
`identify “calling attributes” as all relating solely to PSTN systems. Some profile “attributes” are
`
`clearly non-PSTN-related on their face, such as “reseller 273” and “max number of concurrent
`
`calls 277.”29 Second, as Defendants reluctantly admit, it is a “fact that certain calls may be
`
`completed on the private network without interfacing with a PSTN.”30 Subscriber-to-subscriber
`
`calls that dial, e.g., “IDD” and “NDD,” can be placed solely over the system’s private network
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`without any recourse to, or traversal over, the PSTN. Thus, contrary to Defendants, such attributes
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`do not relate to a PSTN system; rather, they relate to the internal operation of the patentee’s private
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`system. At best, some “attributes” may imitate dialing digits that are typically used in PSTN
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`systems—but they still relate to the patentee’s non-PSTN system. Third, Defendants did not
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`dispute VoIP-Pal’s assertion that the assignment and use of “attributes” in the patentee’s system
`
`need not follow PSTN conventions. Within the patentee’s system, the Calgary subscriber, having
`
`
`26 See Dealertrack, Inc. v. Huber, 674 F.3d 1315, 1327 (Fed. Cir. 2012); see also Kara Tech Inc.
`v. Stamps.com Inc., 582 F.3d 1341, 1348 (Fed. Cir. 2009) (“we will not… import a limitation from
`the specification into the claims.”).
`27 Dkt. No. 75 at 6.
`28 Id. at 5.
`29 Dkt. No. 71 at 13.
`30 Dkt. No. 75 at 6.
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`5
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 10 of 16
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`a PSTN area codes of “403”, can be nonetheless dialed using a non-Calgary area code “604.”31 If
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`“area code” (one example of an “attribute”) can be set to violate PSTN conventions, then it is not
`
`information relating to the PSTN. Fourth, Defendants conveniently ignore that the specification
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`discloses placing calls without using any of the profile items that Defendants identify as allegedly
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`PSTN-related “attributes.” For example, the Calgary subscriber also could be called by solely her
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`“username,” which is part of the Calgary subscriber’s profile, but clearly non-PSTN-related.32
`
`Defendants assert that the purpose of the preferred embodiment is to allow PSTN calls, but
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`this purpose is not its sole purpose. Defendants conveniently ignore that another purpose of the
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`preferred embodiment is to allow private network calls that do not use the PSTN system. Thus,
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`the system’s user profiles and their “attributes” cannot be strictly tied to PSTN calling. Indeed, the
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`system would continue to work for subscriber-to-subscriber calls even if untethered from the
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`PSTN. Indeed, most of the claims of the ’606 patent relate to non-PSTN calls. So even though
`
`the overall embodiment permits PSTN destinations, the aspect of communication that is being
`
`claimed by the independent claims is non-PSTN calls. For all these reasons, Defendants’ unduly
`
`narrow definition of “profile” should be rejected.
`
`D.
`
`“routing message”
`
`
`
`Defendants assert that “routing message” is “defined” by Fig. 15, and that “nothing in the
`
`patent identifies Fig. 15 as limited to a particular embodiment.”33 Defendants’ argument should
`
`be rejected as a matter of law. Drawings in a patent need not illustrate the full scope of the
`
`invention.34 Arguing, as Defendants do, that the term routing message is limited by Fig. 15
`
`
`31 See https://cnac.ca/area_code_maps/canadian_area_codes.htm (last visited May 6, 2022)
`(showing that “604” is a PSTN area code that is not assigned to Calgary, which is in the province
`of Alberta, but rather, area code “604” is assigned to the province of British Columbia).
`32 See Dkt. No. 67-3 at Fig. 11, 23:8-22, Fig. 8B (402); Dkt. No. 71 at 13.
`33 Dkt. No. 75 at 6.
`34 See Arlington Industries, Inc. v. Bridgeport Fittings, Inc., 632 F.3d 1246, 1254 (Fed. Cir. 2011).
`6
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 11 of 16
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`precisely invokes the dangers of importing limitations from the specification into the claims that
`
`the Federal Circuit has expressly warned against:
`
`[P]atent coverage is not necessarily limited to inventions that look like the ones in
`the figures. … To hold otherwise would be to import limitations onto the claim
`from the specification, which is fraught with danger.”35
`
`
`Nowhere does the patent state that Fig. 15 is an exhaustive definition of “routing message.”
`
`Rather, it states expressly that only “embodiments” are being “illustrate[d]” in the Figures.36
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`Further, the patent indicates that Fig. 15 shows a particular “type” of routing message,
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`implying that other “types” are possible.37 Still further, some examples of routing messages given
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`in the patent do not comport with Defendants’ narrow, unsupported construction, nor do they
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`strictly follow Fig. 15 as some sort of “template.” For example, Fig. 32 goes well beyond the
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`format in Fig. 15 in several ways such as repetition of fields (e.g., multiple routes) and includes
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`additional fields not provided for in Fig. 15. Thus, Fig. 15 is not a specification for all routing
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`messages. Even if the specification describes the routing message in Fig. 15 as “generic,” this
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`description does not make it definitional; “generic” merely means that Fig. 15 does not illustrate a
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`specific routing scenario to a specific network address—unlike Figs. 16, 25, and 32.
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`E.
`
`“private network”
`
`The Court should adopt VoIP-Pal’s proposed construction of “private network” because it
`
`is consistent with the intrinsic record. Defendants’ brief admits that VoIP-Pal has pointed out
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`examples in the specification of using the public Internet as part of a “private network”
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`communication path, but Defendants say that these examples have “no relevance” as to the
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`meaning of “private network.”38 On the contrary, they do. If the specification shows that the
`
`
`35 See MBO Labs., Inc. v. Becton, Dickinson & Co., 474 F.3d 1323, 1333 (Fed. Cir. 2007).
`36 See Dkt. No. 67-3 at 11:9-10, 45-47.
`37 Id. at 25:11-13.
`38 Dkt. No. 75 at 8.
`
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`7
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 12 of 16
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`“private network” can proceed over the Internet, then this supports VoIP-Pal’s contention that a
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`“private network” can function on the Internet without having complete control of every computer.
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`Defendants’ argument about “private network” relates to two stray passages in which a
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`private network is contrasted with the public Internet.39. These two passages, however, refer to
`
`generic private networks and are not attempts to specifically describe the “private network” of the
`
`invention; nor do these two passages deny that a network element or node that is on the Internet
`
`cannot be part of a “private network” (in the sense of the invention). Defendants’ two stray
`
`passages simply cannot overcome the overwhelming weight of intrinsic evidence that a “private
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`network,” within the scope of the invention, can include privately controlled network elements
`
`accessible over the Internet.40 An intra-node “private network call,” such as illustrated by a routing
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`message in Fig. 32, involves sending messages, audio and/or video by using IP addresses on the
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`Internet.41 The specification also discloses various mechanisms of control of such “private
`
`network” calls. The term “private network” can mean different things, but a POSITA could easily
`
`determine which sense of “private network” is intended by the invention by the clear and consistent
`
`examples of usage of “private network” in the patent.42 The description makes clear, and would
`
`be understood by a POSITA as clarifying the sense of “private network” as “a network for
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`communication that is privately controlled.”43
`
`
`39 Id. (citing 1:29-31 and 14:5-6).
`40 See, e.g., Dkt. No. 67-3 at Fig. 1 (devices 12, 15 communicating via the Internet 13 to call
`controller 14, media relay 9, etc.), 13:55-57, 14:1-17, 14:18-63, 15:35-47. It is expressly stated
`that supernodes can be “Internet based” (14:41; cf. Fig. 16 and 32 (routes identified by Internet
`domain address)).
`41 Dkt. No. 67-3 at 27:48-52, 28:20-44.
`42 See, e.g., id. at 2:5-8, 2:59-64, 3:1-23, 15:1-7, 20: 64-21:2, 21:24-34; 23:8-22; 23:40-49.
`43 Dkt. No. 71-4 at ¶30.
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 13 of 16
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`Notably, Defendants have retreated from their original position that “nothing in the
`
`specification links the idea of a ‘private network’ to ‘control’ over components of a network.”44
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`Now, Defendants try to artificially inject confusion into VoIP-Pal’s construction by asking: “how
`
`many or what percentage of machines must be privately controlled to fall within ‘private
`
`network’”?45 The patent illustrates, however, the notion of control to define a “private network”
`
`without specifying any percentage; this notion is something that a POSITA would understand.46
`
`While the Defendants state VoIP-Pal’s definition is “unworkable,” they fail to demonstrate
`
`conclusively that knowledge of how to control a private network would not be within the
`
`knowledge of a POSITA. VoIP-Pal’s construction is based on clear intrinsic evidence whereas
`
`the Defendants’ counterproposal is unclear and potentially inconsistent with the specification.
`
`F.
`
`“gateway”
`
`VoIP-Pal submits that a “gateway” is a device that connects networks, but denies that the
`
`networks must necessarily “use different communication protocols.” Defendants’ unsupported
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`assertion is mere attorney argument that assumes that all gateways convert protocols and cannot
`
`have other purposes such as security, network address translation (NAT), or billing. Elsewhere,
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`Defendants deny that NAT is performed by a gateway, citing VoIP-Pal’s ’721 patent.47 But a
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`router can be a gateway, or alternatively, NAT can be performed by a gateway (“typically” does
`
`not exclude the possibility of using a gateway).
`
`
`
`Defendants misrepresent VoIP-Pal’s argument regarding Bjorsell.48 VoIP-Pal was not
`
`making points about the call controller’s functionality; rather, VoIP-Pal pointed out that Bjorsell
`
`
`
`44 Dkt. No. 67 at 14.
`45 Dkt. No. 75 at 8.
`46 Dkt. No. 71-4 at ¶30.
`47 Dkt. No. 75 at 10 (“a device performing NAT, typically a router”).
`48 Dkt. No. 71 at 17-18.
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 14 of 16
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`discloses that even an IP-based telephone (56) may need a gateway for establishing a call. There
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`is no basis to assume that Bjorsell is describing only one side of a gateway, because the IP phone
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`can call IP-based destinations and, in such cases, the second side of the gateway would also
`
`communicate using the IP protocol. Anyway, Bjorsell also discloses that gateway 18 may not
`
`provide PSTN channels, but instead may provide IP-based channels.49 In this case, both sides of
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`gateway 18 would be IP-protocol-based.
`
`
`
`Defendants also attack VoIP-Pal’s citation to Chu of an example of a “gateway” that has
`
`the same protocol on both sides.50 Defendants demur that this is a “special gateway” that can also
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`be called a “packet switch.”51 But Chu’s special gateway is a “gateway,” whether or not it is
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`“special,” providing a useful counterexample to Defendants’ overbroad assertions that gateways
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`always translate between different protocols. Defendants assert that VoIP-Pal avoids Chu’s
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`description of a “traditional” gateway that ostensibly meets their definition. But this only shows
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`that there are many types of gateways, not all of which are “traditional.” Defendants underscore
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`that this gateway converts to TDM format, but conveniently ignore that Chu also discloses
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`gateways that connect virtual private networks “without conversion to TDM.”52 Neither the ’606
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`patent’s claim language nor the specification limit the term “gateway” to the types of gateways
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`that convert protocols, and neither should this Court.
`
`II.
`
`CONCLUSION
`
`In conclusion, VoIP-Pal respectfully requests that the Court adopt VoIP-Pal’s claim
`
`constructions and reject Defendants’ proposed constructions.
`
`
`
`
`
`
`49 Dkt. No. 67-3 at 9:37-40, 13:49-66, 18:49-53.
`50 Dkt. No. 75 at 10.
`51 Id.
`52 Dkt. No. 71-3 at 4:20.
`
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 15 of 16
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`Respectfully submitted,
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`/s/ Lewis E. Hudnell, III
`HUDNELL LAW GROUP P.C.
`Lewis E. Hudnell, III
`lewis@hudnelllaw.com
`Nicolas S. Gikkas
`nick@hudnelllaw.com
`800 W. El Camino Real Suite 180
`Mountain View, California 94040
`T: 650.564.3698
`F: 347.772.3034
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`ATTORNEYS FOR PLAINTIFF
`VOIP-PAL.COM, INC.
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`Dated: May 6, 2022
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`Case 6:20-cv-00272-ADA Document 72 Filed 05/06/22 Page 16 of 16
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`CERTIFICATE OF SERVICE
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`I certify that on May 6, 2022, I electronically filed the foregoing with the Clerk of Court
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`using the CM/ECF system, which will send notification of such filing to all counsel of record.
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`/s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
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